Chamber of Commerce v. Environmental Protection Agency
395 U.S. App. D.C. 193
| D.C. Cir. | 2011Background
- Chamber of Commerce and NADA challenged EPA’s waiver granting California preemption relief under the Clean Air Act for California’s greenhouse gas standards.
- California’s standards apply fleet-wide and are tied to regulation of manufacturers, not dealers.
- EPA granted the waiver in July 2009 after reconsideration of its 2008 interpretation of 7543(b)(1)(B).
- National standards for MYs 2012–16 were issued April 2010, with California deeming its standards compliant with those national standards.
- Petitioners sought judicial review in the D.C. Circuit; the court dismissed for lack of jurisdiction, finding mootness given subsequent federal standards and California’s alignment.
- The court emphasized Article III jurisdiction and associational standing problems, concluding the dispute was not sufficiently concrete or imminently threatened to sustain review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court has jurisdiction to review the waiver decision | Chamber and NADA argue EPA erred in interpreting § 7543(b)(1)(B) and violated CAA preemption. | EPA and California contend the case is moot due to subsequent national standards and lack of a live dispute. | No jurisdiction; petition for review dismissed as moot. |
| Whether petitioners have standing to challenge the waiver | Associational standing on behalf of dealer members; alleged future injury from mix-shifting and price increases. | Evidence insufficient to show imminent injury to identified dealer members; third-party action by manufacturers complicates causation. | Lacking standing; even if associational standing considered, injuries not shown to be imminent or properly traceable. |
| Whether the case remains live given subsequent federal standards | Waiver decision remains actionable despite federal standards. | National standards render California’s waiver moot and any remaining claims speculative. | Moot; petition dismissed for lack of live controversy for MYs 2012–16. |
Key Cases Cited
- Steele Co. v. Citizens for a Better Env’t., 523 U.S. 83 (U.S. 1998) (jurisdiction and standing principles under Article III)
- Preiser v. Newkirk, 422 U.S. 395 (U.S. 1975) (advisory opinions and mootness principles)
- Summers v. Earth Island Inst., 129 S. Ct. 1142 (U.S. 2009) (standing and injury-in-fact requirements)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (standing elements: injury, causation, redressability)
- Bennett v. Spear, 520 U.S. 154 (U.S. 1997) (standing proof burden; substantial probability of injury)
- Sierra Club v. EPA, 292 F.3d 895 (D.C. Cir. 2002) (association standing and injury to members)
- Munsingwear, 340 U.S. 36 (U.S. 1950) (vacatur and mootness considerations on review)
- National Black Police Ass’n v. District of Columbia, 108 F.3d 346 (D.C. Cir. 1997) (standing and mootness considerations for associations)
- Center for Biological Diversity v. U.S. Dep’t of Interior, 563 F.3d 466 (D.C. Cir. 2009) (standing require record evidence of imminent injury)